COLA submissions

First of all, big thanks to my favorite beverage law blog – BevLog – for bringing this to my attention. It appears that the often fearless Daniel Shelton, of famed beverage importer Shelton Brothers, has decided that the “queen mother of dirty words” (thanks Ralph) no longer meets the definition of “obscene or indecent.” Because if that “F – – -” word was, the TTB certainly would not approve of it.

Thanks to Danish brewer To Ol and Shelton Brothers, we are getting a sneak peak at the TTB’s new line of thinking. I am virtually certain that the TTB didn’t simply miss that word in its review – because the same word appears in 4 different submissions for the same brewery.

Personalized labels are desirable, just like this one done for my son's birth.

At least one time in your life as a brewer, you will be asked to make a beer for a friend’s event. A wedding, a graduation, an anniversary – whatever. But, your friend will want you to make a custom label.

Under the old rules, a brewer was required to request a label approval for every single variation of your beer’s labels. Not anymore. Luckily, the TTB has decided to relax its requirements and allow brewers to use already-approved personalized labels with different graphics. That means that your approval for “30 Year Old Doug” might work for “Jess and Doug’s Anniversary Ale.”

….for personalized labels, it has long been our policy to permit the holder of an approved COLA to change items such as salutations, names, and event dates on the label without applying for a new COLA. Our 2010-1 guidance did not allow certificate holders to change the artwork or graphics on personalized labels without resubmission of the labels for approval. We have reconsidered this requirement and now permit certificate holders to make changes to the graphics or artwork on a previously approved personalized label without having to apply for a new certificate of label approval.

So, if you are planning on offering personalized bottles for your customers, remember these important rules. First, you must submit a COLA application for a personalized label template. On the application (item 19 of the paper application) you must advise the TTB that you are requesting a personalized template, stating the parts of the label that may change from label to label.

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